Navigating the evolving sustainability reporting landscape: A roadmap for corporates

Sustainability reporting in India is moving from a regulatory requirement to a strategic imperative. What began as a regulatory disclosure exercise has evolved into a core element of corporate strategy, driven by SEBI’s Business Responsibility and Sustainability Reporting (BRSR) framework and growing expectations of investors.

As international frameworks such as sustainability-related disclosure standards (IFRS Sustainability Disclosure Standards) issued by International Sustainability Standards Board (ISSB) and the EU’s Corporate Sustainability Reporting Directive (CSRD) gain traction, Indian companies face a new reality: aligning domestic compliance with global expectations while maintaining clarity, efficiency and credibility.

This shift matters because reporting obligations are expanding beyond home-jurisdiction requirements. In several markets, the scope of regulation extends not only to listed entities but also, in certain cases, to large non-listed entities, subsidiaries, branches and value-chain participants. At the same time, investors, lenders and other stakeholders increasingly expect comparable, decision-useful sustainability information that can be understood across markets.

India’s sustainability reporting journey: From BRR to BRSR

India has been among the early adopters of structured ESG reporting frameworks in emerging markets.

• 2012–2020: Business Responsibility Reporting (BRR) introduced for large, listed entities.
• 2021 onwards: Business Responsibility and Sustainability Reporting (BRSR) introduced by SEBI, aligned with global ESG expectations.
• Current phase: Mandatory reporting and assurance or assessment³ on BRSR Core, a focused subset of sustainability KPIs accompanied by assurance requirements. The assurance requirement is applicable in a phased glide path manner, beginning with the top 150 listed entities for FY23-24, expanding to the top 250 for FY24-25, the top 500 for FY25-26 and the top 1,000 thereafter.

³ SEBI has not issued any standard on assessment yet.

BRSR represents a significant shift in India’s sustainability reporting landscape — moving from largely narrative disclosures to quantitative, metric-driven reporting, from voluntary reporting practices to mandatory requirements for top listed companies, and from standalone ESG disclosures to deeper integration with corporate strategy and decision-making frameworks. It also provides a foundation for Indian companies to build broader reporting systems capable of supporting multiple frameworks where required.

While BRSR provides a strong domestic foundation, Indian corporates, especially with a global presence, must now navigate a reporting landscape in which sustainability-related requirements are proliferating across jurisdictions, often with different scope thresholds, reporting boundaries, implementation timelines and assurance expectations. The direction of travel is toward greater convergence, but not toward complete uniformity. The ISSB Standards are increasingly serving as an important global reference point for investor-focused reporting, yet many jurisdictions are adopting them with local adaptations or embedding them into existing legal and listing-rule structures.

The requirements in most jurisdictions apply to listed entities in that jurisdiction. However, some also require large non-listed entities to comply. As a result, entities with multinational operations may have subsidiaries or other components that are or will be required to report sustainability-related information and value chain entities that may need to provide underlying data. Global frameworks are also gaining relevance as investors increasingly demand comparable, decision-useful disclosures across markets and as Indian companies integrate deeper into global supply chains.

This means the real challenge for companies is not simply choosing a reporting framework. Rather, it is designing a reporting model that can support multiple frameworks at the same time. A group may report primarily under BRSR in India, face climate-reporting requirements at a subsidiary level in Australia, monitor ISSB-aligned climate expectations in Singapore and assess potential ESRS-based obligations in Europe.

In practice, the primary challenge frequently lies not in preparing disclosures, but in determining whether an organization possesses the necessary systems, controls, governance frameworks and data architecture to produce dependable information across various reporting perspectives.

Entities with multinational operations need to understand which regulations apply to them, comply with relevant reporting requirements, and assess how these frameworks may affect their reporting strategies, processes and internal controls.

Jurisdictional perspectives on sustainability reporting

European Union (EU)

The EU’s Corporate Sustainability Reporting Directive (CSRD) significantly expands sustainability reporting by requiring in-scope entities to disclose information in line with the European Sustainability Reporting Standards (ESRS). The scope of the CSRD is far-reaching and affects non-EU-based public and private entities with operations in the EU through subsidiaries or branches in the EU. In addition, the CSRD contains certain reporting requirements that only apply to non-EU entities. Non-EU entities that have subsidiaries in scope but that are not listed have several reporting options under the CSRD, including reporting at the ultimate parent level.

The EU position has changed materially through the Omnibus I simplification process. By July 2026, the European Commission had adopted revised ESRS designed to reduce the number of companies and datapoints in scope. Groups therefore reassess applicability under the latest rules⁴.

Implementation is being phased in, with many non-EU group subsidiaries expected to begin reporting in 2028 (for FY27 data), followed by consolidated non-EU parent reporting from 2029 (for FY28 data). Importantly, CSRD also introduces a requirement for mandatory limited assurance on sustainability disclosures, to be provided by the statutory auditor or another accredited independent assurance provider, reinforcing the reliability of reported information⁵.

For Indian companies, the practical implication is clear: where there is meaningful EU activity — through subsidiaries, branches, listings or customer relationships — CSRD cannot be treated as a distant European development. It may affect reporting obligations directly, or indirectly influence expectations around data quality, governance and value-chain visibility.

⁴ Source: https://finance.ec.europa.eu/news/commission-adopts-revised-sustainability-reporting-standards-reduce-administrative-burdens-eu-2026-07-03_en

⁵ Refer to related Technical Line publication, How the EU’s Corporate Sustainability Reporting Directive affects non-EU based multinationals, for the latest developments.

IFRS sustainability disclosure standards

The IFRS Foundation established the International Sustainability Standards Board (ISSB) in November 2021 at COP26 to develop a global baseline of sustainability-related disclosure standards focused on the needs of investors and capital markets. In June 2023, the ISSB issued its first two standards — IFRS S1, which sets out general requirements for sustainability-related financial disclosures, and IFRS S2, which specifically addresses climate-related risks and opportunities — together forming the foundation for consistent and decision-useful reporting.

The ISSB is continuing to expand its agenda, including research projects on biodiversity, ecosystems and human capital, reflecting the evolving scope of sustainability risks. Adoption momentum is building globally, with a growing number of jurisdictions either adopting or progressing toward implementation, positioning ISSB Standards as an emerging global baseline for sustainability disclosures, though timelines and extent of adoption vary across regions.

Australia

Australia provides a good example of a jurisdiction adopting ISSB-aligned climate reporting through domestic legislation and standards. New climate-related financial reporting rules commenced on 1 January 2025 and are being phased in. In-scope entities that prepare financial reports under Chapter 2M of the Corporations Act and meet the relevant thresholds are required to prepare sustainability reports containing climate-related disclosures in accordance with AASB S2, while AASB S1 remains available on a voluntary basis. Importantly for multinational groups, Australian requirements generally operate at the reporting-entity level, which means an Australian subsidiary of a non-Australian parent may not always satisfy its local compliance obligations simply by relying on the parent’s consolidated report.

This is a useful reminder for Indian-headquartered groups that consolidated sustainability reporting at the parent level does not necessarily eliminate local reporting requirements. Entity-level filing and jurisdiction-specific reporting obligations can still arise, even where the group already publishes broader sustainability disclosures.⁵

Singapore

Singapore has adopted a phased approach toward ISSB-aligned climate reporting. The roadmap developed by Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo) provides for climate-related disclosures for listed issuers from FY25, building on an earlier Task Force on Climate-related Financial Disclosures (TCFD)-based regime and progressively embedding ISSB-style climate requirements into listing rules. This illustrates how jurisdictions are not always adopting the full ISSB package in a single step; instead, some begin with climate-related disclosures and expand over time.

For Indian groups with Singapore-listed entities, regional operations or financing platforms, this phased model reinforces the need for flexible reporting systems. Companies need to be able to support climate-first requirements today while remaining adaptable to broader sustainability disclosure expectations tomorrow.

Where voluntary frameworks still matter

Many companies already undertake voluntary sustainability reporting using established frameworks such as the Global Reporting Initiative (GRI) and, historically, TCFD-aligned climate reporting, often on a consolidated basis. These frameworks continue to be relevant, particularly for broader stakeholder communication and international benchmarking.

However, the more important strategic issue is no longer whether a company reports under one framework or another; it is whether the organization’s underlying systems can support mapping, reconciliation and consistency across frameworks that may differ in scope, concepts and materiality.

That is why the next phase of maturity is not simply “more disclosure” but a stronger reporting infrastructure. Companies need processes that can capture data once, apply common definitions, preserve audit trails and translate outputs across BRSR, ISSB-aligned requirements, ESRS-style expectations and relevant voluntary frameworks. Interoperability — not framework silos — will increasingly determine both reporting efficiency and reporting credibility.

⁴ Source: https://finance.ec.europa.eu/news/commission-adopts-revised-sustainability-reporting-standards-reduce-administrative-burdens-eu-2026-07-03_en

⁵ Refer to related Technical Line publication, How the EU’s Corporate Sustainability Reporting Directive affects non-EU based multinationals, for the latest developments.

IFRS sustainability disclosure standards

The IFRS Foundation established the International Sustainability Standards Board (ISSB) in November 2021 at COP26 to develop a global baseline of sustainability-related disclosure standards focused on the needs of investors and capital markets. In June 2023, the ISSB issued its first two standards — IFRS S1, which sets out general requirements for sustainability-related financial disclosures, and IFRS S2, which specifically addresses climate-related risks and opportunities — together forming the foundation for consistent and decision-useful reporting.

The ISSB is continuing to expand its agenda, including research projects on biodiversity, ecosystems and human capital, reflecting the evolving scope of sustainability risks. Adoption momentum is building globally, with a growing number of jurisdictions either adopting or progressing toward implementation, positioning ISSB Standards as an emerging global baseline for sustainability disclosures, though timelines and extent of adoption vary across regions.

Australia

Australia provides a good example of a jurisdiction adopting ISSB-aligned climate reporting through domestic legislation and standards. New climate-related financial reporting rules commenced on 1 January 2025 and are being phased in. In-scope entities that prepare financial reports under Chapter 2M of the Corporations Act and meet the relevant thresholds are required to prepare sustainability reports containing climate-related disclosures in accordance with AASB S2, while AASB S1 remains available on a voluntary basis. Importantly for multinational groups, Australian requirements generally operate at the reporting-entity level, which means an Australian subsidiary of a non-Australian parent may not always satisfy its local compliance obligations simply by relying on the parent’s consolidated report.

This is a useful reminder for Indian-headquartered groups that consolidated sustainability reporting at the parent level does not necessarily eliminate local reporting requirements. Entity-level filing and jurisdiction-specific reporting obligations can still arise, even where the group already publishes broader sustainability disclosures.⁵

Singapore

Singapore has adopted a phased approach toward ISSB-aligned climate reporting. The roadmap developed by Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo) provides for climate-related disclosures for listed issuers from FY25, building on an earlier Task Force on Climate-related Financial Disclosures (TCFD)-based regime and progressively embedding ISSB-style climate requirements into listing rules. This illustrates how jurisdictions are not always adopting the full ISSB package in a single step; instead, some begin with climate-related disclosures and expand over time.

For Indian groups with Singapore-listed entities, regional operations or financing platforms, this phased model reinforces the need for flexible reporting systems. Companies need to be able to support climate-first requirements today while remaining adaptable to broader sustainability disclosure expectations tomorrow.

Where voluntary frameworks still matter

Many companies already undertake voluntary sustainability reporting using established frameworks such as the Global Reporting Initiative (GRI) and, historically, TCFD-aligned climate reporting, often on a consolidated basis. These frameworks continue to be relevant, particularly for broader stakeholder communication and international benchmarking.

However, the more important strategic issue is no longer whether a company reports under one framework or another; it is whether the organization’s underlying systems can support mapping, reconciliation and consistency across frameworks that may differ in scope, concepts and materiality.

That is why the next phase of maturity is not simply “more disclosure” but a stronger reporting infrastructure. Companies need processes that can capture data once, apply common definitions, preserve audit trails and translate outputs across BRSR, ISSB-aligned requirements, ESRS-style expectations and relevant voluntary frameworks. Interoperability — not framework silos — will increasingly determine both reporting efficiency and reporting credibility.

Conclusion

The real transformation in sustainability reporting is not merely the growth of disclosure requirements; it is the shift from fragmented, framework-specific compliance to a more integrated reporting model underpinned by stronger systems, clearer governance and assurance-ready information. Companies that move early from compliance-driven reporting to integrated, system-driven and assurance-ready sustainability reporting will be best positioned to navigate the rapidly evolving global landscape.